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Convention on the other hand, where payments in excess of the "minimum amount" are withdrawn in a year, such payments would not even fall under the definition of "pension" because the definition found in Article XVII(3) excludes: "... any payment under a retirement plan... in settlement of all future entitlements... ...

Chief Services, Public Utilities & Exempt Corporations Section Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch ...

In addition, a review of Falconbridge on "Banking and Bills of Exchange" states on page 759 that "... a "deposit" could, depending on the contractual terms, refer to money loaned to a bank in exchange for any kind of document evidencing such indebtedness, including... bank passbooks". ...

(c) Since a partnership is by definition "... the relation that subsists between persons carrying on business in common with a view to profit" (paragraph 2 of IT-90) it is our view that the sale of assets to a corporation by the LP followed shortly thereafter by a sale of the capital shares by the LP could also be an adventure in the nature of trade. ...

According to the Canadian Alamanac & Directory 1988 Copp Clark Pitman Ltd. ...

It is our view that in situations 1, 2 & 4 above, the payments are subject to Part XIII tax under subsection 212(5) of the Act. ...

We would agree that the "right" and the "warrant" would both be considered to be "... a right to buy additional shares... ...

" would be subject to the purpose test of subsection 55(2) of the Act. ...

These rates are as follows: Year % of premium 1977 and prior 0 1978 2 1979 4 1980 6 1981 8 1982 10 1983 12 1984 14 1985 16 1986 18 (d) (i) A farm mutual would be eligible for the small business deduction provided it was throughout the taxation year a Canadian- controlled private corporation. ...

Yours truly, for Director Business and General Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch Document Disclosed Pursuant to the Access to Information Act Document Divulgué en vertu de la loi sur l'accès à l'informationLANGIND E DOCNUM AC59569 REPLACES TYPEKEY R AUTHORDV LEGS AUTHOR JJONES DESCKEY 5 RATEKEY 1 REFDATE 900329 ETADYEAR ETADSORT ADMINACC LEGS ACCESSLV LEGS99 SUBJECT Nursing home fees SECTION ITA-118.2(2)(d) SECTION SECTION SECTION SECTION $$$$ 5- 9569 19(1) J.D. ...